Information on the processing of personal data pursuant to art. 13 of EU Regulation 679/2016

International Educational and Commercial Consultancy Ltd., Block M Suit 9, POWA Plaza, Nyanya Abuja FCT as Data Controller (hereinafter also “IECC” or “Data Controller”) pursuant the Nigeria Data Protection Act 2023 “NDPA” (referred to as Regulation”) – has privacy and the protection of personal data at heart as this is one of the main objectives of its business. Before communicating any personal data to the Owner, we invite all Users of the IECC website to carefully read this Privacy Policy which contains important information on the protection of their personal data.

This information describes the management methods of the IECC website (www.internationaleducationaleducationalandcommercialconsultancyldt.com, hereinafter: “Site”) and not of other external websites that can be consulted by the user via links. Further information may be provided within the various access channels, divided according to the topics covered (Thematic Areas).

This policy:

  • constitutes an integral part of the Site;
  • is made pursuant to Part V, Articles 24 – 33; Part VI, Articles 34 – 38 of the Regulation.
  • in some sections of the site, and where necessary, it is integrated with detailed provisions in relation to the specific processing of personal data.

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The processing of personal data will be based on the principles of correctness, lawfulness, transparency, purpose limitation and conservation, minimization and accuracy, integrity and confidentiality, as well as the principles of accountability and responsibility referred to in art. 37 (3 a, b, c) of the Regulation. Users’ personal data will therefore be processed in accordance with the legislative provisions of the Regulation and the confidentiality obligations provided therein.

Processing of personal data means any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form of making available, comparison or interconnection, limitation, cancellation or destruction.

The personal data being processed may consist of textual information, photographic or video images and any other information suitable for making the interested party identified or identifiable.

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Data controller and organizational controls

1.2. Data provided voluntarily by the user

The voluntary and explicit sending of e-mails to the addresses indicated in the various access channels of this site and the compilation of the specially prepared “formats” (forms) entail the subsequent acquisition of the address and data of the sender/user, necessary to respond to the requests produced and/or provide the requested service. Specific summary information will be reported or displayed on the site pages set up for particular services on request.

1.3. Third party data voluntarily provided by you

When using particular services, personal data of third parties communicated to IECC by the User may be processed. With respect to these hypotheses, the User acts as an independent data controller, assuming all legal obligations and responsibilities. In this sense, the User grants on this point the broadest indemnity with respect to any dispute, claim, request for compensation for damage resulting from processing that may reach the Data Controller from third parties, whose personal data have been processed through your use of the Site’s services in violation of the applicable legislation on the protection of personal data. In any case, if the User provides or otherwise processes the personal data of third parties in the use of the Site, they guarantee their use – assuming all related responsibilities – that this particular processing hypothesis is based on the prior acquisition – by the User – of the consent of the third party to the processing the information concerned .

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1.4. Cookies

Cookies are small text files that the sites visited by users send to their terminals, where they are stored before being re-transmitted to the same sites on the next visit. They are used for different purposes: performing computer authentication, monitoring sessions, storing information on specific configurations regarding users who access the server, storing preferences, etc.

Among the categories of “cookies” we distinguish the so-called “technical cookies” which serve to allow safe navigation on the site or to provide a service requested by the user. They are not used for other purposes and are normally installed directly by the website owner.

The IECC site uses exclusively session cookies (which are therefore not stored permanently on the user’s computer and disappear when the browser is closed) and can be classified among technical cookies as defined above.
Use is strictly limited to some pages for the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe and efficient exploration of the site.

The IECC site does not acquire any personal data from users. Cookies are not used to transmit information of a personal nature, nor are so to say used as “persistent cookies” of any kind, i.e. systems for tracking users.

In the presence of only technical cookies, the Owner has chosen not to use any banner to promote the short cookies policy on the home page but to provide the relevant information as part of this privacy policy. This choice complies with the indications Nigeria data Protection Commission for the protection of personal data.

  1. Purpose of the processing

The IECC Site processes personal data within the limits of what is strictly necessary for the performance of institutional functions, excluding processing when the purposes pursued can be achieved using anonymous data or methods that allow identification of the interested party only in case of necessity.

Specific purposes, relating to individual treatments, may be reported in detail within the different access channels. Within them the User can find further information on the processing of personal data.

The personal data collected through the IECC website may be used, with the consent of the interested party, to:

  1. insert in the database thecandidates for job positions;
  2. request to send information material.
  3. Treatment methods

Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they are collected. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access (see  Part VII art. 39 of the Regulation).

  1. Optional provision of data

The user is free to provide personal data contained in the request forms for the various services offered on the portal; failure to provide the mandatory data requested will make it impossible to obtain the service.

  1. Transfer, communication and dissemination of personal data

Data can be transferred within the areas of the services in full respect of the extant laws on the subject-matter.

The personal data of Users who request the sending of informative material (mailing lists, answers to questions, notices and newsletters, deeds and measures, etc.) are used for the sole purpose of carrying out the service or provision requested and are communicated to third parties only in cases where:

  • this is necessary for the fulfillment of requests (e.g. shipping service of the requested documentation);
  • communication is required by legal or regulatory obligations;
  • during legal proceedings.

The processing connected to the web services of this site is handled both by IECC technical personnel, in charge of processing, and by external technical personnel as part of a specific service contract.

  1. Storage of personal data

The personal data processed for simple navigation of the Site will be kept for the time strictly necessary for this functionality.

For the purposes referred to in point 2.a. (inclusion in the database of candidates for job positions), personal data will be kept for a period of three years.

For the purposes referred to in point 2.b. (request to send information material), personal data will be kept for a period of two years.

Further information regarding the data retention period and the criteria used to determine this period can be requested by sending a written request to the Data Controller at info@internationaleducationalandconsultancyldt.com.

In any case, IECC remains entitled to retain the personal data of Users for the period of time envisaged and permitted by the Nigerian legislation on the subject-matter.

  1. Rights of the interested party

Pursuant to the  Part VI articles 34 – 38 of the NDPA, Users have the right to ask IECC at any time, for access to their personal data, for rectification or cancellation of the same, or to oppose their processing pursuant to Part X, art. 46 of the Regulation. Users also have the right to request the limitation of processing in the cases provided for by the …, as well as to obtain the data concerning you in a structured format, commonly used and readable by automatic device, in the cases provided for by the Regulation.

Requests must be sent in writing to the Data Controller a info@internationaleducationalandcommercialconsultancyldt.com. 

In any case, Users always have the right to lodge a complaint with the competent authority (Nigeria Data Protection Commission, pursuant to Part X, Art. 46), if they believe that the processing of their data is contrary to the legislation in force.

  1. Changes

IECC reserves the right to modify or simply update the content of this Privacy Policy, in part or completely, also due to changes in applicable legislation.

IECC will inform Users as soon as they are introduced and they will be binding as soon as they are published on the Site.

IECC invites Users to regularly visit this section to become aware of the most recent and updated version of the Privacy Policy in order to always be updated on the data collected and the use that IECC makes of it.

  1. Contacts

To exercise the above rights or for any other request you can write to the Data Controller:

IECC based in Nigeria at info@internationaleducationalandcommercialconsultancyldt.com  

Copyright 2021 – International Educational and Commercial Consultancy Ltd. (IECC)

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